State Of Louisiana v. Miranda Cheyenne Gilley, 308 So.3d 1194

On July 11, 2017, Miranda Cheyenne Gilley fatally stabbed Jessica McGehee at an apartment complex; the victim was unarmed and died of multiple stab wounds.
The victim had been in a long-term relationship with William Alexander, who was also seeing Gilley; social-media/contact disputes preceded the encounter.
Multiple eyewitnesses testified Gilley threatened to stab the victim, retrieved a knife, and stabbed the victim repeatedly; some described the victim on top of Gilley during parts of the altercation.
Gilley (105 lbs) testified she carried a folding knife, claimed the victim (larger) attacked and was on top of her, and asserted she pulled and swung the knife to get the victim off her (claiming self-defense).
A jury convicted Gilley of manslaughter (a responsive verdict) by an 11–1 vote; she was sentenced to 23 years at hard labor.
The court of appeal found the evidence sufficient to support a murder conviction but vacated and remanded the manslaughter conviction and sentence because the non‑unanimous (11–1) verdict violated the Sixth and Fourteenth Amendments under Ramos v. Louisiana.

Issue	State's Argument	Gilley’s Argument	Held
Sufficiency of the evidence to support manslaughter/second‑degree murder	Evidence (wounds, number/depth of stab wounds, witness accounts, threats) shows specific intent to kill or inflict great bodily harm; rejects self‑defense	Actions were defensive—knife swung to stop an ongoing assault; lacked intent to kill	Evidence was sufficient to support murder; jury rejected self‑defense; appellate court will not reweigh credibility
Jury instruction on justifiable homicide/self‑defense	Not specifically argued beyond urging rejection of self‑defense	Trial court erred by not fully instructing jury on justifiable homicide	Addressed only after sufficiency; court found jury reasonably rejected self‑defense; defendant not entitled to acquittal; error claim rendered moot by later disposition
Excessiveness of 23‑year hard labor sentence	Sentence within statutory range and justified by facts	Sentence excessive given defendant’s size, claimed self‑defense, and circumstances	Merits not reached—deemed moot after vacatur/remand for non‑unanimity
Validity of non‑unanimous 11–1 verdict	Non‑unanimous verdict was valid under prior Louisiana practice	11–1 guilty verdict violates Sixth and Fourteenth Amendment after Ramos	Court applied Ramos; conviction and sentence vacated and case remanded (Ramos applies to convictions not final on direct review)

Jackson v. Virginia, 443 U.S. 307 (constitutional standard for sufficiency review)
Ramos v. Louisiana, 140 S. Ct. 1390 (Sixth Amendment requires unanimous jury verdicts for serious offenses; applies to convictions on direct review)
Apodaca v. Oregon, 406 U.S. 404 (overruled by Ramos regarding non‑unanimous verdict precedents)
State v. Hearold, 603 So. 2d 731 (La. 1992) (framework for appellate sufficiency review and order of review)
State ex rel. Elaire v. Blackburn, 424 So. 2d 246 (La. 1982) (discussion of compromise/responsive verdicts)
State v. Captville, 448 So. 2d 676 (La. 1984) (circumstantial‑evidence review; hypothesis of innocence rule)
State v. Ordodi, 946 So. 2d 654 (La. 2006) (appellate sufficiency principles)